People v. Campos
REITERATIONFacts
The Antecedents: The National Bureau of Investigation (NBI), upon tip from International Justice Mission, surveilled Freda's KTV Bar in Cebu owned by Wilfreda Laput Campos a.k.a. Freda, suspecting trafficking of minors for sexual exploitation. In October 2014, undercover Agent Rey Villordon posed as customer 'Kuya Bernie,' confirmed with Campos that bar fine of P2,000 per girl allowed taking them out for sex, paid for AAA, BBB, and CCC (16-year-old minor), but only took them to eat. On November 7, 2014, entrapment: Villordon negotiated P4,000 for all three girls explicitly for sex, handed marked money dusted with fluorescent powder to Campos who accepted and pocketed it, triggering arrest; powder test positive, two marked bills recovered via serial numbers. Victims AAA (Campos's daughter's live-in partner and aunt of BBB/CCC), BBB, CCC testified they worked due to poverty, promised lodging/commissions, knew 'taking out' meant sex, recruited by Campos/DDD, bar fine for sexual services confirmed. Pre-trial: Campos admitted ownership and CCC's minority but claimed ignorance of age. Procedural History: RTC Branch 6, Cebu convicted Campos of qualified trafficking under Sec. 4(a)/(e) r.a. Sec. 6(a)/(c) RA 9208 as amended (large scale, minor victim), sentenced life imprisonment sans parole, P2M fine, P500k moral + P100k exemplary each victim at 6% interest. CA affirmed in toto, noting elements proven: recruitment (BBB testimony), means (vulnerability/minority), purpose (bar fines for sex), entrapment credible, minority knowledge irrelevant. SC required supplemental briefs; OSG filed for appellee. The Petition: Campos appealed arguing no proof of sex purpose (only meals), guilt based solely on uncorroborated Villordon testimony, no coercion, ignorance of CCC's age bars qualification, BBB never prostituted, bar fine just for expenses outside bar.
Issue(s)
Whether the prosecution proved beyond reasonable doubt all elements of qualified trafficking in persons under Section 4(a) and (e) in relation to Section 6(a) and (c) of RA 9208, as amended by RA 10364. Whether actual prostitution or knowledge of victim's minority is required for conviction and qualification.
Ruling
Appeal dismissed. CA Decision affirmed. Accused guilty beyond reasonable doubt of qualified trafficking; sentenced to life imprisonment, P2,000,000 fine, P500,000 moral and P100,000 exemplary damages each to AAA, BBB, CCC at 6% interest from finality; delete 'without eligibility for parole'.
Ratio Decidendi
On proof of elements of qualified trafficking: All elements present: (1) Act of obtaining/hiring/offering proven by AAA's recruitment testimony, victims' confirmation of Campos's ownership/control, and entrapment where Campos offered three girls for sex at P4,000 bar fine (Villordon testimony: 'primarily for sex,' accepted marked money). (2) Means: exploited financial vulnerability (jobs/lodging amid poverty, per victims) and CCC's minority (birth certificate, age 16; People v. De Dios: vulnerability of minors suffices without force). (3) Purpose: sexual exploitation via bar fines explicitly for 'taking out for sex' (Villordon's detailed Q&A testimony corroborated by victims recalling events; entrapment caught in flagrante). Large scale (three victims, Sec. 6(c)); qualified by minor (Sec. 6(a)). RTC/CA correctly held positive prosecution evidence (officer + victims) overcomes denial; entrapment vital in trafficking per jurisprudence. On actual prostitution and minority knowledge: Unnecessary; Ferrer v. People: crime consummated by recruitment/offering for prostitution purpose, punishing acts to prevent trafficking—no need for actual sex/dancing/GRO work. Bandojo: knowledge of minority 'inconsequential' for Sec. 6(a) qualification once proven by birth certificate alleged in Info. Penalty proper under Sec. 10(e) (life + P2M-P5M fine); damages justified analogously to seduction/abduction (Art. 2219 CC, People v. Lalli), interest per Jugueta; no parole phrase needed (A.M. 15-08-02-SC).
Main Doctrine
Trafficking in persons under Section 3(a) of RA 9208, as amended, is committed by recruitment, obtaining, hiring, providing, offering, maintaining, or harboring persons by means of fraud, deception, or taking advantage of vulnerability for exploitation including prostitution or sexual exploitation, with elements expanded in People v. Casio to include the act, means, and purpose. The crime is consummated upon the prohibited acts without requiring actual sexual intercourse, as held in Ferrer v. People, punishing the facilitation itself to prevent trafficking. For qualified trafficking under Section 6(a) and (c), involvement of a minor (proven by birth certificate) qualifies regardless of the accused's knowledge of age, per People v. Bandojo, and large-scale commission against three or more persons elevates the penalty to life imprisonment and fine of P2M-P5M under Section 10(e). Means such as exploiting financial vulnerability or minority suffice, even without threat or force, and entrapment operations providing in flagrante delicto evidence via marked money and fluorescent powder are crucial, corroborated by victim testimonies. Ownership of the establishment and receipt of bar fines explicitly for 'taking out for sex' establishes purpose, distinguishing from mere employment.